3. Site Selection Methodology and Consideration of AlternativesSite Selection Methodology and Consideration of Alternatives
3.1. IntroductionIntroduction
- This section discusses the site selection and alternatives of the Array which have been considered by the Applicant. The stages of site selection that have been carried out to establish the Array will be further outlined in the Array Environmental Impact Assessment (EIA) Report. In addition, any refinements to the Array that have taken place resulting from the EIA process and in response to consultation and stakeholder feedback will be included in the Array EIA Report, and the reasonable alternatives that have been considered as part of this process will be discussed.
3.2. Site Selection And Consideration Of AlternativesSite Selection And Consideration Of Alternatives
- CES announced its intention to launch a leasing round for commercial scale offshore wind energy projects within Scottish waters in November 2017 (Scottish Government, 2020a). The first ScotWind Leasing Round was subsequently launched by CES in June 2020. The ScotWind Leasing Round allowed developers to apply for the rights to build offshore wind farms in Scottish waters within specified lease areas, with up to 25 GW of new generating capacity expected to be built over the following ten years. The application window for registered applicants opened in January 2021 and closed in July 2021, with Option to Lease Agreements offered in January 2022.
- In October 2020, the Scottish Government published the Sectoral Marine Plan (SMP) for Offshore Wind Energy which provided a strategic framework for the ScotWind Leasing Round (Scottish Government, 2020a). The SMP identified 15 final Plan Options (POs) across four regions for renewable energy generation, with a national limit on generating capacity of 10 GW.
- These final POs were developed through an iterative process. The first steps included identification of initial Areas of Search (AoS) which were subsequently refined through several iterations of Opportunity and Constraint Analysis, and consultation and engagement with key sectoral stakeholders, Scottish Ministers, the SMP Project Board and Project Steering Groups. From this, 17 revised AoS were selected as Draft Plan Options (DPOs) (Scottish Government, 2020a).
- The DPOs were subject to a Sustainability Appraisal process, comprising a Strategic Environmental Assessment (SEA), Habitats Regulations Appraisal (HRA) and Social and Economic Impact Assessment (SEIA), which examined cross-sectoral impacts of the DPOs to support sustainable development of renewable energy generation in Scottish waters. Statutory consultation was held between 18 December 2019 and 25 March 2020 to seek feedback on the DPOs. A Consultation Analysis Report was produced to inform the Scottish Ministers' decision on which DPOs to progress (Scottish Government, 2020d). Following this, the SMP was published, and the refined, final POs were identified within this (Scottish Government, 2020a).
- The SMP noted that there was potential for regional cumulative impacts on bird populations, benthic habitats, cetaceans, navigational safety, seascape/landscape, and commercial fisheries, however, the level of impacts are likely to vary depending upon the final POs developed. The SMP provides several mitigation measures regarding potential impacts at various scales (Scottish Government, 2020a).
- The SMP was developed in accordance with the aims of the National Marine Plan (NMP) (Scottish Government, 2015) and sits alongside the Scottish Offshore Wind Energy Policy Statement (OWEPS) (Scottish Government, 2020b) to build a framework towards Scotland’s sustainable green recovery. It should be noted that the SMP is subject to an iterative review process (Scottish Government, 2020a).
- The Applicant applied for the rights to develop an offshore wind farm within the E1 PO Area in the first ScotWind Leasing Round, and was subsequently awarded an Option to Lease Agreement for the site boundary, within which the Array will be located, in January 2022. The Applicant applied to develop the site boundary within the E1 PO Area based on a detailed review of number of parameters and constraints (SSER, Marubeni and CIP, 2021) including:
- water depth and distance to shore;
- wind speed and metocean conditions;
- offshore geotechnical conditions;
- offshore environmental designations (existing and proposed) including Special Protection Areas (SPAs), Ramsar sites, Sites of Special Scientific Interest (SSSIs), Special Areas of Conservation (SACs) and Nature Conservation Marine Protected Areas (NCMPAs);
- ornithology;
- offshore habitats;
- benthic ecology, including epifauna and infauna;
- fish and shellfish ecology;
- marine mammals including cetaceans and seals;
- shipping and navigation
- commercial fishing effort;
- seascape and landscape;
- archaeology and cultural heritage;
- aviation and radar, including civil and military aspects;
- existing infrastructure and oil and gas leases;
- energy generation;
- emergency services, including search and rescue (SAR) operations; and
- cables and pipelines.
- The site boundary was selected by the Applicant for application after undergoing a site assessment process which used measured baseline data from Berwick Bank, Seagreen 1 (formerly known as Seagreen Alpha and Bravo), and Seagreen 1A Offshore Wind Farm projects, industry-leading tools including a Levelised Cost of Energy (LCoE) analysis of all 15 of the final POs included in the ScotWind Leasing Round, as well as an assessment of wind resource and energy yield prediction, and drew upon their extensive experience developing offshore wind globally and in Scotland (SSER, Marubeni and CIP, 2021).
- According to the SMP, the key concerns within the E1 PO Area included minor socio-economic impacts to commercial shipping, fishing, power interconnector sectors, and Ministry of Defence (MoD) radar interference, as well as impacts to offshore ornithology (in particular kittiwake Rissa tridactyla and razorbill Alca torda) and fish spawning grounds for herring Clupea harengus, cod Gadus morhua, whiting Merlangius merlangus, plaice and sandeel Ammodytes spp. (Scottish Government, 2020a). Therefore, the Applicant carried out several studies and analyses at the pre-award stage to gain an understanding of the potential constraints associated with the site boundary, as noted in the SMP.
- Analysis was undertaken to understand the metocean conditions within the area, followed by the deployment of metocean buoys within the site boundary in August 2022. The Applicant also assessed the wind and climatic conditions regarding site suitability and project feasibility, and commissioned Atkins to carry out a desktop geological and foundations feasibility assessment of the E1 PO Area. This desktop study concluded that the area of the site boundary was the best location for the development of a floating offshore wind farm based on desk-based data and taking into consideration the various constraints within the region. The Applicant has followed this with an interpretive geophysical survey and environmental survey (including benthic grab sampling and drop down video (DDV)) of the site boundary between March and July 2022. In addition, the Applicant also undertook a desktop study of other infrastructure in the area, including oil and gas, cables and pipelines and energy generation (SSER, Marubeni and CIP, 2021).
- The Applicant began aerial ornithological and marine mammal surveys, prior to award, in February 2021, to gain an understanding of the ornithological and marine mammal baseline. This two-year survey is expected to conclude in February 2023 and will inform the design considerations and layout of the Array which will be taken forward into the Array EIA Report. Regional level ornithological surveys are also in progress, as proposed in the SMP.
- In addition, the Applicant also commissioned several studies at the pre-award stage to gain an early understanding of the potential risks to human receptors within the site boundary, as follows:
- a shipping activity and constraints study, carried out by Anatec Ltd (Anatec Ltd., 2021);
- a fishing intensity and spawning analysis study, carried out by Brown and May Marine Ltd (Brown and May Marine Ltd., 2021); and
- an aviation and military activity study, carried out by Coleman Aviation.
- Further desktop data analysis and studies will be carried out throughout the EIA process and documented in the standalone Technical Reports for the various receptor topics, as well as feeding into the assessments undertaken within the Array EIA Report.
- The Array EIA Report will further describe the background to the ScotWind leasing round process and the evolution of the Array within the site boundary. In addition, the Array EIA Report will outline the process followed by the Applicant to identify potential wind turbine layouts and other infrastructure forming part of the Array application including Offshore Substation Platforms (OSPs), inter-array cables and interconnector cables, the reasonable alternatives that were considered, and the rationale for the selection of the final project design considering any modifications identified during consultation.
- In 2020, the Offshore Transmission Network Review (OTNR) was launched by the UK Government and is currently ongoing. The purpose of the OTNR is to ensure that the network connections for offshore wind generation are delivered efficiently and consider environment, cost to consumers, local communities and deliverability (HM Government, 2022a; National Grid, 2022a). In April 2022, the UK Government released the British Energy Security Strategy policy paper which sets out the ambition to deliver up to 50 GW of offshore wind by 2030, including up to 5 GW of floating offshore wind (HM Government, 2022b). To achieve this ambitious target, it is necessary that a coordinated approach with regard to the offshore grid network and landfall points is put forward. As part of the OTNR, National Grid have developed the Pathway to 2030 Holistic Network Design (HND) to set out a coordinated approach for connecting 23 GW of offshore wind (National Grid, 2022a). The findings of the HND will feed into a Detailed Network Design (DND) which will be taken forward by the organisation(s) responsible for developing that part of the network, and a HND Follow Up Exercise (HNDFUE) will be undertaken by National Grid to include the remaining ScotWind leaseholders, any capacity available through the ScotWind clearing process, and 4 GW of Celtic Sea Floating Offshore Wind (FLOW) capacity (National Grid, 2022b).
- Due to the ongoing nature of the OTNR and HNDFUE, and the uncertainty associated with landfall grid connection points, the Applicant has made the decision for the Proposed offshore export cable corridor(s) and Proposed onshore export cable corridor(s) (and associated onshore transmission infrastructure) to be subject of separate applications once the outcomes and/or further information of these reports are available.
4. Environmental Impact Assessment MethodologyEnvironmental Impact Assessment Methodology
4.1. IntroductionIntroduction
- This section presents the methodology that will be applied to the Array Environmental Impact Assessment (EIA) Report. The methodology for the identification and assessment of likely significant environmental effects, as defined in the EIA Regulations (The Marine Works (Environmental Impact Assessment) Regulations 2007; see Appendix 4), is discussed in this section, alongside the proposed methodology for the identification and assessment of cumulative and inter-related impacts, including consideration of potential transboundary effects. The methodology will follow a systematic and auditable evidence-based approach to assess and interpret the potential effects on physical, biological and human receptors within the offshore environment.
4.2. Basis of AssessmentBasis of Assessment
4.2.1. EIA Legislative Basis and Guidance DocumentsEIA Legislative Basis and Guidance Documents
- In order to comply with applicable law and policy (see Appendix 4) and in particular with the Marine Works (Environmental Impact Assessment) Regulations 2007 and the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017, an EIA Report will be prepared when applying for Section 36 consent and marine licence(s) for the Array, as discussed within section 1.5 and Appendix 4. A separate EIA Scoping Report and EIA Report will be produced for the Proposed offshore export cable corridor(s). In addition, a separate EIA Scoping Report and EIA Report will be prepared for the planning permission application(s) for the Proposed onshore export cable corridor(s) and associated infrastructure (above MLWS).
- The following Regulations will also be considered in the production of the Array EIA Report, in addition to the EIA Regulations described in section 1.5 and Appendix 4:
- the Conservation of Habitats and Species Regulations 2017; and
- the Conservation of Offshore Marine Habitats and Species Regulations 2017 (which apply to marine licences and Section 36 applications within the Scottish Offshore region).
- Guidance and good practice documents have also been developed, in addition to the legislative requirements, to assist with the production of a ‘fit for purpose’ EIA. These include:
- Marine Scotland Consenting and Licensing Guidance: For Offshore Wind, Wave and Tidal Energy Applications[4] (Marine Scotland, 2018);
- Guidelines for Ecological Impact Assessment (EcIA) in the UK and Ireland – Terrestrial, Freshwater, Coastal and Marine (Chartered Institute of Ecology and Environmental Management (CIEEM), 2022);
- Environmental Impact Assessment for offshore renewable energy projects (British Standards Institute (BSI), 2015);
- Guidelines for data acquisition to support marine environmental assessments of offshore renewable energy projects (Centre for Environment, Fisheries and Aquaculture Science (Cefas), 2012);
- A Review of Assessment Methodologies for Offshore Wind Farms (Collaborative Offshore Wind Research into The Environment (COWRIE) METH-08-08) (Maclean et al., 2009);
- Institute of Environmental Management and Assessment (IEMA) Environmental Impact Assessment Guide to Shaping Quality Development (IEMA, 2015);
- Planning Advice Note (PAN) 1/2013 Environmental Impact Assessment (Scottish Government, 2013);
- A Handbook on Environmental Impact Assessment (NatureScot, 2018);
- Advice Note Seventeen: Cumulative effects assessment relevant to nationally significant infrastructure projects (The Planning Inspectorate, 2019); and
- Cumulative Impact Assessment Guidelines - Guiding Principles for Cumulative Impact Assessment in Offshore Wind Farms (RenewableUK, 2013).
- It should also be noted that there are a number of guidance documents which are in the process of being issued or consulted on by NatureScot and MS-LOT in the near future. The Applicant will monitor for, review, and endeavour to adhere to new guidance, where relevant, in the Array EIA Report.
4.2.2. The Environmental Impact Assessment ProcessThe Environmental Impact Assessment Process
- The EIA process broadly consists of:
- EIA Screening: The Applicant assesses whether an EIA is required for the Array, based on the thresholds and criteria of the project against the Schedules within the EIA Regulations. The Array is considered a Schedule 2 project as it is classed as an “Installation for the harnessing of wind power for energy production (wind farm)” (HM Government, 2007). The Applicant can submit a request for a Screening Opinion from the Scottish Ministers, however, the Applicant has chosen to voluntarily prepare an EIA Scoping Report and EIA Report for the Array without a Screening Opinion following the steps below;
- EIA Scoping: The Applicant produces an Offshore EIA Scoping Report for the Array (this document) and requests a formal Scoping Opinion from Scottish Ministers;
- Consultation: The Applicant will undertake stakeholder engagement during the pre-application period;
- EIA Report preparation: The Array EIA Report will be prepared. This will consider the responses to the consultation process and the outcomes of the assessment of the likely significant effects (as defined in EIA Regulations (see section 1.5) of the Array during the construction, operation and maintenance, and decommissioning stages of the project lifecycle;
- EIA Report consultation: The Applicant is required to publicise the Array EIA Report (and the application to which it relates) to allow the consultation bodies and the public to be given the opportunity to provide their views about the Array EIA Report, including the project design;
- Determination: The competent authority is required to examine all the environmental information, including the Array EIA Report, as well as any comments and representations received from consultation bodies and the public, to enable them to reach a reasoned conclusion on the significant effects of the Array on the environment. The competent authority must consider the environmental information and the conclusions reached, and whether any monitoring measures are appropriate when making the decision whether or not to give consent for the Array; and
- Decision notice: The competent authority is required to inform the public and the consultation bodies of the decision and must publish a ‘decision notice’ incorporating the authority’s reasoned conclusion on the significant effects of the development on the environment.
- Figure 4.1 Open ▸ provides an overview of the Section 36 and marine licensing process and illustrates how the EIA Scoping stage fits within this process.
Figure 4.1: Stages of the Licensing Process in Scottish Waters
4.3. Key Principles of the EIAKey Principles of the EIA
4.3.1. OverviewOverview
- Within the Array EIA Report, each topic will consider the following:
- identification of the study area for the topic-specific assessments;
- description of the planning policy and guidance context;
- summary of consultation activity, including comments received in the Array Scoping Opinion and all other engagement undertaken during the pre-application phase;
- description of the environmental baseline conditions; and
- presentation of impact assessment, which includes:
identification of the MDS for each impact assessment;
a description of the mitigation and design measures implemented as part of the Array which aim to prevent, reduce or offset environmental effects;
identification of likely impacts and assessment of the significance of identified effects, considering any measures implemented as part of the Array;
identification of any secondary mitigation measures (IEMA, 2016) required regarding likely significant effects (as defined by the EIA Regulations and in addition to mitigation measures implemented as part of the Array), alongside a consideration of any residual effects;
identification of any future monitoring required;
Cumulative Effects Assessment (CEA) with any other developments, including those that are proposed, consented and under construction, and projects, plans or activities that are currently operational that were not operational when baseline data was collected (if applicable); and
transboundary effects assessment for any potential transboundary effects on European Economic Area (EEA) states.
- A separate standalone section will assess inter-related effects (i.e. inter-relationships between environmental topic areas). This section will include a receptor based inter-related effects assessment of the Array on each of the identified receptor groups, as well as an ecosystem-based assessment which will provide a qualitative assessment of the impacts of the Array at the ecosystem level to assess any effects on predator – prey relationships and the functioning of the ecosystem.
- A number of key principles will be applied within each topic section. These are detailed in sections 4.3.2 to 4.3.8 below.
4.3.2. Proportionate EIAProportionate EIA
- This Scoping Report has been developed using a number of tools and processes with the aim of producing a proportionate EIA Report for the Array (as per IEMA (2017), and the Industry Evidence Programme (IEP) (Crown Estate et al., 2018)). These tools and processes will also be applied within the Array EIA Report.
- Figure 4.2 Open ▸ presents the general approach taken for proportionate EIA in this Scoping Report.
- The tools and processes noted in paragraph 153 include the following:
- development of a draft Stakeholder Engagement Plan;
- application of the existing evidence basis; and
- commitment to designed in measures.
Draft Stakeholder Engagement Plan
- The dSEP has been developed to enable engagement throughout the pre-application phase (see Appendix 1).
- The purpose of the dSEP is to allow stakeholders to plan resources to ensure post-scoping consultation is focused, direct and progresses in an efficient manner.
- As noted in paragraph 176, pre-Scoping workshops were held with key stakeholders in November 2022 to present the baseline characterisation and data sources for a range of topics. Feedback and points of agreement from these workshops have been considered and presented within this Scoping Report for the relevant sections. Further information on these workshops can be found in paragraph 176 and Appendix 1.
- Post-Scoping consultation will be used to discuss development and agreement of modelling methodologies to be used, interpretation of significance, application of new guidance, and/or agreeing the level of technical assessment which will be presented for impacts within the Array EIA Report. This will ensure that the Array EIA submission documents will be focused on likely significant effects (as defined by the EIA Regulations). The dSEP is considered a ‘live’ document which will be reviewed and updated in response to feedback from stakeholders as part of their Scoping representations.
- At the time of writing this Scoping Report, the following topics have been identified in the dSEP as requiring focused post-Scoping consultation, subject to scoping feedback:
- benthic subtidal ecology (post-Scoping consultation expected to be minimal);
- fish and shellfish ecology;
- subsea noise and marine mammal ecology;
- offshore ornithology;
- commercial fisheries; and
- shipping and navigation.
- In addition, there may be the need to discuss the approach to CEA and any queries raising from soon to be published guidance which may affect the approach taken in the Array EIA Report.
- The section labelled “next steps” within each topic section of this Scoping Report, details the proposed approach for post-Scoping stakeholder engagement in line with the appended dSEP (see Appendix 1).
Existing evidence basis
- As noted in section 3, the site boundary was subject to an extensive site assessment process through the development of the SMP, followed by the Applicant’s site assessment process pre-ScotWind award. This existing baseline data and site-specific information has been drawn upon to inform this Scoping Report and the subsequent Array EIA Report. In addition, site-specific information from Berwick Bank Offshore Wind Farm and other Scottish offshore wind farms in the vicinity of Ossian has been considered as part of the pre-ScotWind award site assessment process undertaken by the Applicant, as well as preliminary site-specific survey data for the Ossian site boundary, including digital aerial survey data, and geophysical and environmental survey data. Each technical section of this Scoping Report includes a detailed desktop review which aims to:
- provide an initial high-level summary of the baseline environment;
- provide an overview of the existing data to support the Array EIA Report;
- provide rationale for scoping out of impacts from the Array EIA Report where there is clear evidence to do so (e.g. lack of a receptor-impact pathway); and
- provide the existing evidence base to support scoping in of impacts to the Array EIA Report, where appropriate.
- Offshore digital aerial surveys for ornithology and marine mammals were completed between March 2021 and February 2023. Metocean surveys are ongoing (due to be completed in August 2023), and geotechnical surveys are planned to commence in late Q1 2023 which will further inform the Array EIA Report and final project design.
Designed in measures and mitigation measures
- There are three different forms of mitigation including:
- Primary mitigation (inherent): “Modification to the location or design of the development made during the pre-application phase that are an inherent part of the project, and do not require additional action to be taken” (IEMA, 2016).
- Secondary mitigation (foreseeable): “Actions that will require further activity in order to achieve the anticipated outcome. These may be imposed as part of the planning consent, or through inclusion in the ES” (IEMA, 2016).
- Tertiary mitigation (inexorable): “Actions that would occur with or without input from the EIA feeding into the design process. These include actions that will be undertaken to meet other existing legislative requirement, or actions that are considered to be standard practices used to manage commonly occurring environmental effects” (IEMA, 2016).
Designed in measures (primary and tertiary mitigation)
- The term ‘designed in measures’ has been used to refer to primary and tertiary mitigation within this Scoping Report. The design of the Array has been informed via this iterative approach to the environmental impact assessment process, through the identification of likely significant effects (as defined by the EIA Regulations) and development of designed in measures to address these. Through the incorporation of designed in measures, the Applicant’s commitment to implementing the identified measures is demonstrated. These are referred to as designed in measures throughout this Scoping Report and the subsequent Array EIA Report.
- This approach ensures that the significance of effect presented in throughout this Scoping Report and the subsequent Array EIA Report represents the maximum residual effect that the Array will have, should the application for consent be approved and the Array be constructed.
- Both primary and tertiary mitigation measures are considered as designed in measures as they are incorporated as part of the project design. Therefore, the Environmental Impact Assessment (EIA) can be undertaken assuming that these designed in measures will be implemented during the relevant project phase. As a result, potential effects which might arise prior to the implementation of designed in measures do not need to be identified as potential effects as there is no potential for them to arise (IEMA, 2016). It should be noted that in each topic specific section of this Scoping Report, a full list of potential impacts without application of designed in measures has been presented, alongside a refined list of impacts proposed to be scoped in and out of the Array EIA Report after application of designed in measures. The topic specific designed in measures are presented in each topic receptor section.
- Section 2.7 presents all designed in measures considered in this Scoping Report. The development of mitigation measures will continue as the EIA progresses and in response to stakeholder engagement. An iterative process will be used for any additional measures and the dSEP will be updated (Appendix 1).
Secondary mitigation
- Secondary mitigation is a flexible form of mitigation that can be proposed at any point within the EIA process, including during the decision-making process (IEMA, 2016). As noted above, this form of mitigation requires further activity, particularly at the post-consent stage. Therefore, secondary mitigation measures are additional measures applied after completion of the assessment process to prevent, reduce and offset likely significant effects (as defined by the EIA Regulations) which could not be avoided through designed in measures.
4.3.3. Design Envelope Approach and Maximum Design ScenarioDesign Envelope Approach and Maximum Design Scenario
- In accordance with current good practice and the “Rochdale Envelope Principle[5]”, the assessment of the Array will utilise the PDE approach (also known as the Rochdale Envelope approach). The PDE concept allows for some flexibility in final project design options within a maximum design, where the full details of a project are not necessarily known when the application is submitted.
- The PDE parameters are set out in section 2, where the maximum project design values for relevant components of the Array are identified. The PDE considered will be the scenario which would give rise to the greatest potential impact (hereafter referred to as the MDS) for each of the topic sections within the Array EIA Report, and for each of the impacts assessed.
- The Applicant has undertaken a process of PDE refinement prior to submission of this Scoping Report. Therefore, the assessment which is presented in the final application will be based on a PDE which is as refined and focused as is practical whilst still retaining a degree of flexibility for new technology or design solutions in the post-consent phase.
4.3.4. Consultation and Stakeholder EngagementConsultation and Stakeholder Engagement
Background
- Appendix 4, section 4.5.2 notes that there is no legislative basis for undertaking Pre-application Consultation (PAC) as the Array application is located in Scottish offshore waters (12 nm to 200 nm), however, the PAC Regulations are considered good practice for undertaking public engagement.
- An overview of consultation undertaken to date is presented in Appendix 1. Paragraphs 176 to 182 outline the Applicant’s proposed approach to stakeholder engagement to be followed during the pre-application period.
Engagement to date
- Pre-Scoping stakeholder engagement has been undertaken to support the development of this Scoping Report. Consultation has included general project introductions to key stakeholders and regulators; discussions on proposed survey methodologies; pre-scoping engagement on the Array; interim updates with key Statutory Nature Conservation Bodies (SNCBs) and stakeholders, and updates on interim data results for topics such as ornithology, commercial fisheries and shipping and navigation. In addition, the Applicant held pre-Scoping workshops with SNCBs in November 2022 to present the approach to scoping of the Array and to gain feedback on the scoping in/out of specific impacts to key receptors. Topics covered in the workshops included physical processes, benthic ecology, fish and shellfish ecology, marine mammal ecology and subsea noise, offshore ornithology, seascape, landscape and visual resources and cultural heritage, shipping and navigation, and commercial fisheries.
- An overview of the stakeholders engaged with to date is provided below:
- NatureScot;
- MS-LOT;
- Marine Scotland Science (MSS);
- Royal Society for the Protection of Birds (RSPB);
- Maritime Coastal Agency (MCA);
- Northern Lighthouse Board (NLB);
- North and East Coast Regional Inshore Fisheries Group (NECRIFG);
- Scottish Fishermen's Federation (SFF); and
- Scottish White Fish Producers Association (SWFPA).
Future engagement
Array Scoping
Pre-Application Consultation event
- The PAC Regulations apply where activity is planned within Scottish territorial waters and require Applicants for a ‘prescribed class’ of activity to notify the MCA, NLB, NatureScot, and any delegate for a relevant marine region. The Array is located within Scottish offshore waters, therefore, there is no requirement under the PAC Regulations for the Applicant to notify delegates about the proposed activities within the Array. However, the Applicant proposes to follow the principles of the PAC Regulations for the Array as these Regulations are considered good practice for undertaking public engagement.
- The Applicant proposes to hold at least one pre-application event, for example, in the form of a public exhibition, where these bodies, other stakeholders, and members of the public may engage with and provide comments to the Applicant. It is proposed that this public exhibition event is held in 2023 and further details of this event will be advertised.
- Where appropriate to do so and if sufficient information on the grid connection and onshore elements of the project are available, public consultation will be carried out for the onshore and offshore elements at the same event, in order to give third parties a full understanding of the whole project.
Additional stakeholder engagement
- Consultation with key statutory and non-statutory stakeholders throughout the pre-application process will continue as set out in the dSEP (Appendix 1) and on agreement with stakeholders. The Array EIA Report will provide a summary of key consultation undertaken, including the outcomes of the public exhibition.
4.3.5. Impacts and EffectsImpacts and Effects
- A range of impacts and effects regarding the physical, biological and human environment, for offshore receptors, have the potential to arise from the Array infrastructure and activities. Where a change is caused by an action, this is defined as an ‘impact’, for the purposes of the Array EIA Report. For example, the installation of moorings and anchoring systems (action) is likely to result in temporary and/or long term seabed loss and disturbance (impact). Impacts may be direct, indirect, temporary, irreversible, secondary, cumulative and inter-related, and can also be either positive or negative. However, the relationship between them can be complex.
- The consequence of an impact is defined using the term ‘effect’. Further elaborating on the example presented above, the installation of moorings and anchoring systems (action) results in temporary and/or long term seabed loss (impact), which may have the potential to disturb benthic habitats and lead to mortality or injury of benthic species (effect). The significance of effects is defined by considering both the magnitude of impact and the sensitivity of each receptor/receptor group.
- The extent, duration, frequency and reversibility of an impact are considered when determining the magnitude of an impact. For the purposes of the Array EIA Report, the physical or biological resource, or user group that may be affected by the potential impacts are defined as ‘receptors’. When determining the sensitivity of each receptor/receptor group, a number of factors may be considered, including the vulnerability, recoverability and value/importance of the receptor.
- A matrix approach will be applied in the Array EIA Report to ensure a consistent approach is taken when defining the significance of an effect ( Table 4.1 Open ▸ ). Where a range is suggested for the significance of effect, for example, minor to moderate, it is possible that this may span the significance threshold. The technical specialist’s professional judgement will be applied to determine which outcome defines the most likely effect, which takes in to account the sensitivity of the receptor and the magnitude of impact. The technical specialist will provide an explanation for this determination in the relevant section of the Array EIA Report where applicable.
Table 4.1: Matrix Used for the Assessment of the Significance of the Effect